PRIVACY POLICY

This Privacy Policy describes the personal data processing carried out by AUDIOVISUAL GLOBAL NETWORK S.L. ("AGN"), which is adapted to Organic Law 3/2018, dated 5 December, on Personal Data Protection and guaranteed digital rights, and Regulation (EU) 2016/679 of the European Parliament and Council, dated April, 27th, 2016, on the protection of natural persons in terms of personal data processing and the free circulation of this data.

1. Data Controller

2. Data Protection Rights

The data subject may send written communications to the Data Protection Officer (whose contact information is included in section 1 above) in order to request exercising the following rights:

In all cases, the data subject must indicate their first name, surname(s), contact address, and must also include a photocopy of their National ID or Passport with any request. The data subject may obtain more information on the afore mentioned rights, as well as the forms to exercise these rights, on the website of the Agencia Española de Protection de Datos ('Spanish Data Protection Agency', www.agpd.es).

If the data subject has granted their consent for any specific purpose, they have the right to withdraw their consent granted at any time, notwithstanding the lawfulness of processing based on the consent originally provided.

If the data subject feels that their rights have been infringed upon in terms of the protection of their personal data, especially when they have not been able to exercise their rights to their satisfaction, they may lodge a complaint with the Agencia Española de Protección de Datos via its website (www.agpd.es).

3. International Transfers and Recipients

Unless legally required to do so, or with express consent from the data subject, AGN will never transfer any personal data internationally. If it is necessary to make a transfer to a third party, it will be carried out in strict compliance with AGN's legal, professional, and conduct obligations.

Within the scope of the professional services that AGN provides, as well as for the execution of contracts with clients and suppliers, AGN may communicate personal data to third parties, including:

- Third parties to which personal data must be communicated, such as judges, tribunals, arbitrators, courts, and arbitration associations, public administrations, counterparties, auditors, accountants, consultants, surveyors, private investigators, lawyers, legal representatives, registrars, and other professionals in the legal realm; ….

- entities from the financial realm, such as financial institutions, collection agencies, credit rating agencies, defaulter lists; and

- AGN service providers, such as IT providers, accountants, auditors, document storage, ………………………….

AGN contracts virtual infrastructure services and cloud storage from providers that may have servers in countries outside the European Union that offer a level of protection that is less than that stipulated in the data protection regulation in effect in Spain. These AGN providers include:

The data subject expressly accepts the processing of their personal data by AGN through the aforementioned cloud storage and virtual infrastructure services. The data subject can withdraw their consent at any time.

4. Types of Data Maintained by AGN

4.1 Client Data

Purpose: AGN will store personal data for providing services requested by any client or potential client. Normally, the scope of such services will be stipulated in the engagement letter signed between AGN and the client. AGN may also process personal data on a pre-contractual basis, such as for the purpose of preparing a service proposal for clients or potential clients.

Storage Period: In all cases, the personal data of clients and potential clients will be stored while the legal relationship with AGN is maintained, and thereafter until the client or potential client requests its suppression.

In no case may the client or potential client exercising their rights condition or limit (i) the execution of a contract between AGN and any legal obligations derived therefrom; and (ii) the payment obligations that the client or potential client may have with AGN. Therefore, AGN may deny such client or potential client rights until the corresponding contract ends, the corresponding conduct and legal obligations are met, any debts to AGN are paid, and/or any legal actions derived from any of the aforementioned are complete (e.g. arbitral, judicial, or administrative actions).

Legitimation: AGN is legitimised to store personal data in order to execute the engagement letter (contract) that is signed between AGN and the client, as well as any pre-contractual actions (e.g. preparing a service proposal). In addition, AGN is legitimised by the client's consent, which will be reflected in the engagement letter that is signed between AGN and the client.

Communicating personal data is an essential requirement for signing the engagement letter, and therefore the client must provide AGN with this information. If the client does not facilitate their personal data, AGN may decline to sign the engagement letter, refrain from beginning to provide its services, and/or terminate the legal relationship at any time.

4.2 Supplier Data

Purpose: AGN will store personal data for receiving the services provided by any service provider or potential service provider. Normally, the scope of such services will be stipulated in the service provision contract signed between AGN and the service provider. AGN may also process personal data on a pre-contractual basis, such as for the purpose of requesting a service proposal for service providers or potential service providers.

Storage Period: In all cases, the personal data of service providers and potential service providers will be stored while the legal relationship with AGN is maintained, and thereafter until the service provider or potential service provider requests its suppression.

In no case may the service provider or potential service provider exercising their rights condition or limit (i) the execution of a contract between AGN and any legal obligations derived therefrom; and (ii) the payment obligations that the service provider or potential service provider may have with AGN. Therefore, AGN may deny such service provider or potential service provider rights until the corresponding contract ends, the corresponding conduct and legal obligations are met, any debts to AGN are paid, and/or any legal actions derived from any of the aforementioned are complete (e.g. arbitral, judicial, or administrative actions).

Legitimation: AGN is legitimised to store personal data in order to execute the service provision contract that is signed between AGN and the service provider, as well as any pre-contractual actions (e.g. preparing a service proposal). Likewise, AGN is legitimised by the service provider's consent, which may be reflected in the contract signed between AGN and the service provider.

Communicating personal data is an essential requirement for signing the service provision contract, and therefore the service provider must provide AGN with this information. If the service provider does not facilitate their personal data, AGN may decline to sign the service provision contract, refrain from receiving services, and/or terminate the legal relationship at any time.

4.3 Data of Individuals Requesting Information

Purpose: AGN will store personal data and accompanying materials sent by anyone by any means requesting information on AGN services. The purpose will consist of responding to the data subject's consultation.

Storage Period: The personal data of individuals requesting information on AGN's services, or requesting information on a specific question in any other way, will be stored until the data subject withdrawals their consent, unless there is a legal obligation to save personal data for a longer period.

Legitimation: AGN is legitimised to store the personal data of individuals requesting information according to specific consent that all data subjects must return signed. If the data subject refuses to sign the specific consent, their data and materials will be deleted, and the consultation made will not be addressed.

4.4 Data of Users that Connect to AGN's Wi-Fi Network

Purpose: AGN will store the session data of any individual that connects to the Wi-Fi network at their offices. The data that will be stored will include the following information from each device that connects to AGN's Wi-Fi network: name, MAC, IP, channel (Wi-Fi or Ethernet), connection time, connection duration, and browsing information. The purpose will consist of maintaining a log for cybersecurity purposes, as well as blocking unauthorised device connection.

Storage Period: The personal data of individuals that are connected to AGNs Wi-Fi network will be stored for a maximum period of five years.

Legitimation: AGN is legitimised to store the personal data of users connected to AGN's Wi-Fi network according to specific consent that all users must return signed. If the user declines to sign the specific consent, their data will be deleted, and they will not be allowed to connect to AGN's Wi-Fi network.

4.5 Cookies Policy

AGN's webpages use cookies. By browsing and continuing to use AGN's website, the user consents to the use of the cookies described, for the periods indicated, and under the conditions contained in our Cookies Policy. The Cookies Policy of AGN's website can be consulted at ………………... The Cookies Policy is an integral part of this Privacy Policy, however it is presented separately for the sole purpose of data subject convenience.

5. Minors

Those younger than sixteen years of age need express authorisation to send their personal data to AGN and/or exercise the associated data subject rights from a parental authority or guardian. If those younger than sixteen years of age do not have the aforementioned consent, they must refrain from entering their data into AGN's website contact form, or sending AGN communications of any kind. If AGN detects personal data in their files that belongs to a minor without the authorisation described, it will proceed to delete and destroy it, reserving the right to inform the minor's parental authority or guardian.

6. Security Notice

AGN has adopted the obligations and standards of laws in effect on data protection internally. Nevertheless, the security of AGN's systems and its website are not impenetrable, and harmful third-party actions may exist. All personal data and information that a data subject facilitates to AGN will be sent on the data subject's account, and at the data subject's own risk.

7. Modifications

This Privacy Policy was last edited on Otober 2020. AGN reserves the right to change it at any time without prior notice. If there is a change, AGN will report this via email, or through an announcement posted to AGN's website.

Copyright © 2020 Audiovisual Global Network S.L. All rights reserved. Total or partial reproduction of this Privacy Policy is prohibited.